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In October, the NDIA released a new Operational Guideline (OGs) for the delivery of therapeutic supports under the NDIS. The Operational Guidelines are meant to give participants and providers the who, what, when and how rules of therapy support under the NDIS. On the same day, the NDIA also published a new Pricing Arrangement and Price Limits (PAPL) which dropped the rate of art and music therapists from $193.99 per hour down to $156.16 per hour and provided further clarification on who can and can’t bill as an “other professional.”
Therapy providers need to understand the new Operational Guidelines to ensure their services are compliant, billable and sustainable.
There are 8 key concepts in the new Operational Guidelines that providers need to know:
- A 6-point checklist of how the NDIS define an evidence-based support
The NDIS will only fund evidence-based supports. This is the first time the NDIA have let us know the criteria they use to assess whether a support would be considered evidence-based. So, understanding this checklist and how to apply it to practice and therapy recommendations is going to be crucial for allied health professionals. - Recognising the difference between capacity building therapy and maintenance therapy
The new Operational Guidelines provide a definition of the difference between Capacity Building Therapy and Maintenance Therapy. Many allied health professionals have never had to identify the difference between these two types of therapy. Getting this distinction correct will be a crucial factor in getting therapy supports funded into a person’s plan. The definition considers factors such as a person’s life stage and/or diagnosis. - New expectations for Early Childhood therapy providers
It is not uncommon for early childhood therapy providers to work as sole practitioners and, at times, in silo from the rest of the therapeutic team. It is generally accepted that working as part of a multi-disciplinary team is one of the most effective approaches to getting outcomes. Moving forward, the NDIA says that Early Childhood practitioners should follow the National Best Practice Framework for Early Childhood Intervention which includes concepts such as using the key worker model, multi-disciplinary teams and family-oriented practice, among others. - A 7-point compliance checklist for therapy providers
Therapy providers now have a 7-point compliance checklist when delivering services under the NDIS. One HUGE new point is that therapy providers must stick to the PAPL price limits, regardless of how a plan is managed. - Billing for services when delivered by an unpaid supervised allied health student
This is the first time the NDIA have acknowledged the reality that many allied health practitioners supervise allied health students who provide services to NDIS participants. It has now been confirmed that if the session (or part of it) is conducted by the therapy student, but still supervised by the allied health professional, the session can be billed at full price. However, the catch here is that this can only occur if the student is covered under the allied health practitioner’s insurance. This poses a huge problem for allied health as student’s insurance is usually covered by the universities, not the allied health practitioner. - Clarity about the flexibility of funds in the IDL bucket and how and when different allied health professionals can be used
A common point of confusion at the moment is around the flexibility of funds in the IDL bucket. The Operational Guidelines confirm that funding in Improved Daily Living is stated, meaning that it cannot be spent on non-therapy supports. However, you need to examine the description under Improved Daily Living in a person’s plan to see if there’s flexibility in which therapy professions can deliver the support. - Clarity around when a therapy would not be eligible to be billed
The Operational Guidelines now provide a clear list of when a therapy would not be eligible to be billed under the NDIS. This includes things such as online, pre-recorded therapy programs and webinars. This is the first time that the NDIA have provided such a clear list that people can apply to ensure they are only billing for eligible supports. - Confirmation that the NDIA want to see reports detailing the outcomes of the therapy provided
The Operational Guidelines repeatedly refer to the outcomes of the therapy. This highlights that the NDIA really wants to see therapy outcomes clearly outlined in plan reassessment reports, to inform funding levels for the next plan period.
The NDIS operational environment is constantly evolving, and these recent updates directly affect how therapists need to plan, deliver and claim for services.
There’s so much detail we didn’t have space to get into in this article. But come join us in our new workshop where we dive into how to implement these guidelines in practice: New Therapy Operational Guidelines in Practice
